The CAPE Tariff Refund Portal Opens April 20 — What Your Accounting Firm Needs to Do Before Then

Here is what you need to know before that date.

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What CAPE Is — and Why Phase 1 Is Narrower Than Reported

CAPE stands for Consolidation Administration and Processing of Entries. It is CBP's dedicated portal for processing refunds of IEEPA tariff duties — the duties imposed on imports under the International Emergency Economic Powers Act during the most recent tariff escalation.

Phase 1 is not a blanket refund program. It covers two specific categories:

1. Unliquidated entries — import entries that have not yet been finalized by CBP
2. Entries liquidated within the prior 80 days — entries that were finalized, but recently enough to fall within the Phase 1 window

Phase 1 handles approximately 63% of entries with IEEPA duties. The remaining 37% — older liquidated entries — are not covered in Phase 1. Those clients will need to wait for Phase 2 or a future CAPE expansion, the timing of which has not been announced.

Refunds are processed via ACH only. CBP stopped issuing paper checks. If a client does not have ACH banking information on file with CBP, they cannot receive a refund — even if their claim is otherwise valid. Processing timeline after CBP accepts the CAPE Declaration is 60–90 days.

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The Three-Step Eligibility Screen

Before you advise any importer client to file a CAPE claim in Phase 1, run this screen. It takes less than 10 minutes per client and prevents claim denials.

Step 1: Confirm CBP ACE Enrollment

The Automated Commercial Environment (ACE) portal is CBP's primary trade processing platform. Enrollment is required for Phase 1 filing.

When Phase 1 opens on April 20, CBP will reject CAPE Declarations from importers who are not enrolled in ACE. This is not a soft eligibility requirement — it is a hard gate. A client who is not enrolled in ACE cannot file in Phase 1, period.

What to do: Ask each importer client whether they are enrolled in CBP ACE. If they're uncertain, they can verify at the CBP ACE Secure Data Portal. If they are not enrolled, advise them not to file Phase 1 claims. Enrollment takes time; it is unlikely to be resolved before April 20.

Step 2: Confirm Entry Liquidation Status and Timing

Not all entries are in Phase 1 scope. The specific question to answer for each relevant entry:

• Is the entry unliquidated? → Phase 1 eligible
• Was the entry liquidated within the prior 80 days? → Phase 1 eligible
• Was the entry liquidated more than 80 days ago? → Phase 2 (not Phase 1)

For clients with a mix of entry types, Phase 1 claims should only be filed for the eligible entries. Older liquidated entries should be flagged as Phase 2 candidates and held.

What to do: Pull the entry liquidation dates for each importer client with IEEPA duties. Separate Phase 1-eligible entries from Phase 2 entries now. This prevents clients from filing claims that will be rejected — and prevents you from having to explain why a claim failed.

Step 3: Confirm ACH Setup with CBP

Even if a client passes Steps 1 and 2, they cannot receive a refund without ACH banking information on file with CBP. Paper check refunds are gone.

What to do: Ask each eligible importer client whether they have ACH information on file with CBP. If not, they need to set this up before their claim can be processed. The ACH setup is separate from normal banking — it requires CBP's specific process, not just a bank account number.

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What to Do This Week (Before April 20)

The value of this advisory window is real and time-gated. Here is the practical sequence:

By April 15:

• Identify which clients are importers who paid IEEPA tariff duties in the relevant period
• Run the three-step eligibility screen for each: ACE enrollment, entry liquidation status, ACH setup
• Sort clients into three buckets: Phase 1 ready, Phase 1 ineligible (Phase 2 candidates), Phase 1 ineligible (missing prerequisites — ACE or ACH)

By April 18 (two days before launch):

• Contact Phase 1-ready clients: advise them the portal opens April 20, confirm they understand the filing process, and establish whether they want your firm's assistance with the CAPE Declaration
• Contact Phase 1-ineligible clients: brief them on why they don't qualify for Phase 1, what Phase 2 entails, and what steps (if any) they should take now (ACE enrollment, ACH setup)

After April 20:

• Monitor Phase 1 filing confirmation for clients your firm assists
• Watch for CBP announcements on Phase 2 timing
• For clients with older liquidated entries: set calendar reminders tied to Phase 2 news

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What This Opportunity Is, and What It Isn't

This is not a universal windfall for all importer clients. Phase 1 has real constraints:

• It covers only 63% of entries — a significant portion of clients with IEEPA duties may not qualify in Phase 1
• Processing takes 60–90 days after acceptance — this is not immediate cash
• ACE enrollment and ACH setup are prerequisites that take time to resolve

But for clients who do qualify, Phase 1 represents a real refund opportunity on duties already paid — and the accounting firm that identifies their eligibility before April 20 is the one that captures the advisory relationship and the filing work.

The firm that waits until clients ask about CAPE is reacting. The firm that runs the screen this week and calls clients with answers is advising.

That distinction is increasingly the one that separates professional services firms that are growing from those that aren't.

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The CAPE Phase 1 portal opens April 20, 2026. Sources: Forvis Mazars Forsights (April 2026), CBP Official IEEPA Guidance, Baker Tilly, Cherry Bekaert.